Epstein Index›Documents›EFTA00221985
⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00221985: Sullivan, Memorandum and Massage Appointment (DS9)

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The document discusses a legal complaint with two counts: Count I for sexual assault against Jeffrey Epstein, and Count II alleging an intentional tort. The text references legal precedents and suggests the complaint sufficiently establishes a sexual assault and battery claim.

📋 Key Excerpts10

PersonKeyword
Excerpt 1
The Complaint is in two Counts: Count I is labeled "**Sexual** **Assault**", and alleges an intentional tort based on the actions of Jeffrey Epstein; Count II
Excerpt 2
In any event, the Complaint sufficiently alleged a claim for **sexual** **assault** and battery. ¹The Amended Complaint also adds as Count III a federal claim
Excerpt 3
Here, the factual allegations establish an intentional tort claim for **sexual** **assault** and battery.³ See Paul Holbrook, 696 So.2d 1311 (Fla. 5th DCA 1997

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